2. Costs of appeal shall be borne by the Plaintiff.

In the first place, on November 1, 2006, the Defendant imposed the Plaintiff value-added tax of KRW 1,707,340,220 for the second term of 205, value-added tax of KRW 1,149,509,320 for the first term of 2006, and global income tax of KRW 48,318,540 for the first term of 2005, and KRW 48,318,540 for the global income tax of KRW 4,831,850 for the second term of 205.

Preliminaryly, the Defendant’s disposition of imposition of KRW 1,707,340,220 on November 1, 2006 against the Plaintiff on the second half-year value-added tax of KRW 1,149,509,320 on the first half-year value-added tax of KRW 1,506, and global income tax of KRW 48,318,540 on the first half-year basis of KRW 2005, and KRW 48,318,540 on the first half-year basis of KRW 205, shall be revoked.

The reasoning for the court's explanation on this case is as follows: "A evidence No. 85-1, No. 2, No. 86 of the first instance court's ruling", and "A's testimony as witness of the first instance court's ruling is added to "No. 85-1, No. 86 of the first instance court's ruling, No. 87-1, and No. 87-2 of the first instance court's ruling," and the plaintiff's argument in the court's trial is as stated in the reasoning for the first instance's ruling, except for adding the following judgment to the plaintiff's argument in the court's trial, this is cited as it is in accordance with Article 8 (2) of the Administrative Litigation Act and Article 420 of

2. Additional judgment;

The plaintiff can not impose additional tax if there is a justifiable reason that it is impossible for the plaintiff to cause a taxpayer to neglect his/her duty of return, tax payment, etc., and even if the plaintiff deducteds the value of gift certificates provided as gift in calculating the value-added tax on the sales of the game game of this case from the tax base, considering that it is not consistent with the opinion on whether the value-added tax should be deducted in calculating the value-added tax on the sales of the game game of this case, it is reasonable to consider that the case constitutes a case of doubt under the interpretation of tax law. The plaintiff argues that there is a justifiable reason that it is not attributable to the plaintiff's failure to perform his/her duty of return and tax payment, and therefore, at least the part of additional

On the other hand, in order to facilitate the exercise of the right to impose taxes and the realization of tax claims, tax laws are administrative sanctions imposed as prescribed by the law in cases where a taxpayer violates various obligations, such as a return and tax payment, without justifiable grounds, and do not constitute justifiable grounds that do not cause the taxpayer’s intentional intent or negligence (see Supreme Court Decision 2002Du10780, Jun. 24, 2004). According to the overall purport of pleadings, the competent authority appears to have expressed the position that the value of gift certificates should not be deducted from the value-added tax base around January 9, 2006, which was the second time value-added tax return deadline prior to the filing date of the second time value-added tax return in 2005, and it is difficult to readily conclude that the above additional tax constitutes a case of intentional intent under the interpretation of the tax law merely on the grounds that some lower courts decisions were different after the disposition of this case, and it cannot be said that there are justifiable grounds for the Plaintiff to have violated the duty to report and pay taxes (see Supreme Court Decision 20039.

Therefore, there is also no reason for the plaintiff's proposal.

3. Conclusion

Therefore, the judgment of the court of first instance is legitimate, and the plaintiff's appeal is dismissed. It is so decided as per Disposition.